What I’m answering is I’m not going to answer itemized questions on a list that I don’t know how you got, that is at least seven months old, and I don’t have the expertise to answer it. I wasn’t given it before, I wasn’t asked any questions on this. I don’t know. But I’m not going to go in here, because you guys have a great thing of using my depositions and doing other sh¡t with it.

The Debtor lacks any reasonable probability of an effective reorganization.

“The clearest case of bad faith is where the debtor enters Chapter 11 knowing there is no chance to reorganize his business and hoping merely to [stave] off the [evil] day when the creditors take control of his property.” In re James Wilson Associates, 965 F.2d 160 (7th Cir. 1992) In this case, there is no operation to reorganize. The Debtor has no employees with which to operate. The Debtor owns one significant asset, which it has allowed a related company to use for free during at least the past six months. All the while, the Debtor has purposefully evaded all direction from the Brown County Court, and has consistently stonewalled the efforts of the Receiver and creditors to discover the Debtor’s assets. This evidence suggests that the Debtor has no purposeful business operations to reorganize in the first instance.

Law360, Washington (June 13, 2016, 5:22 PM ET) — The U.S. Tax Court has granted a Wisconsin holding company’s request to subpoena the accountants for allegedly deadbeat paper companies as part of the firm’s attempt to establish bad debt deductions in a $17 million fight with the IRS.

Judge Kathleen Kerrigan gave family-owned VHC Inc. the go-ahead to serve a subpoena and notice of deposition on Schenck SC that seek the financial statements and tax returns of clients ST Paper Holdings, Tak Investments and other affiliated companies, according to an order entered last week.

The companies allegedly acquired the debt when they purchased a business formed by an estranged relative of VHC’s founders.

Counsel for the parties could not be reached for comment Monday.

In its March 2015 petition, VHC said it owned debt and not equity in relative Ron Van Den Heuvel’s spinoff business, and that the IRS wrongly increased VHC’s taxable income during the period while disallowing deductions for the debt, which a series of bad deals had rendered illiquid.

VHC, which was first formed as a contracting firm by Ron’s older relative Raymond Van Den Heuvel, underwent “significant expansion” from the 1980s to the 1990s, prompting Ron to form his own company in 1997 and begin buying paper mills and other businesses, the petition said.

Though VHC declined Ron’s solicitations to invest in those firms –– saying doing so would conflict with its customer base –– VHC began issuing debt in the form of promissory notes to Ron’s acquired companies for equipment and overhead costs. The firm cited Ron Van Den Heuvel’s experience as a sales representative for VHC along with potential funding from major banks and companies, including Enron, which ultimately purchased a $5 million stake in his company in 1998, the petition said.

Shortly before 2000, VHC issued a line of credit to Ron’s cotton fiber plant for the installation of a key machine. It did so at the request of United Arab Emirates Investment Ltd., which had made an offer on the plant that would have far exceeded the amount of the company’s debt for the machine. However, UAEI withdrew from the deal at the last minute after the Sept. 11, 2001, terror attacks, saying the status of a Middle Eastern company in the U.S. had become too risky.

About the same time, Enron, one of the debtor’s key backers, filed for bankruptcy.

VHC gave the company even more money following the two collapses to help it get back on its feet, according to the petition.

Starting in 2003, VHC and the debtor company began a series of “often heated” meetings for repayment plans, according to VHC. However, a series of bad deals prevented the payments for years, causing VHC to declare the bad-debt deductions on each year’s tax returns.

In 2007, however, it appeared that the debt would be repaid with an offer on the mill from Goldman Sachs-backed ST Paper, which offered to purchase Ron Van Den Heuvel’s assets. Believing that the deal would bear fruit, VHC waived its bad debt deduction for its 2006 returns. However, VHC recanted when it learned that under a new arrangement, it would receive only promissory notes rather than cash payments for the loans.

These consolidated cases are calendared for a Special Session commencing on August 15, 2016, in Milwaukee, Wisconsin. On May 31, 2016, petitioners filed a motion for leave to serve subpoena and notice of deposition of non-party Schenck, S.C. pursuant to Tax Court Rule 74(c)(2)(B). Attached to the motion, petitioners included the notice of deposition with proof of service. The Court granted petitioners’ motion on June 7, 2016.

Upon due consideration, it is

ORDERED that the deposition of Schenck, S.C. shall take place on June 30, 2016, from 10:30 a.m. to 5:00 p.m., at the offices of petitioners’ counsel, One Law Group, S.C. [formerly doing business as Stellpflug Law, S.C.], 444 Reid Street, Suite 200, DePere, Wisconsin 54115.

It is further

ORDERED that in addition to the usual service, the Clerk of the Court shall serve a copy of this Order on: Dennis J. Langenberg, Schenck S.C., 200 E. Washington Street, Appleton, WI 54911, and on Brian C. Spahn, Godfrey & Kahn, S.C., 780 North Water Street, Milwaukee, WI 53202-3590.

In fact, Michael Garsow’s LinkedIn page has been updated to state that he is currently the Director of Marketing, Sales & Web Services for Reclamation Technology Systems LLC, and he lists the following accomplishments:

Increased sales of pulp and tissue products by over 50% through expanding current converting operations and the newly acquired pulping facility. Building on existing client base as well as acquiring new clients was key to obtaining this sales increase.

Assisted with the acquisition of $400 MM in tax exempt bonds through a well known and respected financial services agency.

Assisting in the acquisition of 10 year off-take agreements for tissue, pulp and linerboard with an estimated value of $1.2 billion dollars.

Reclamation Technology Systems, LLC’s newly created website can be seen at www.ReclamationTechnologySystems.com, and the ‘Contact’ page lists RTS’ address as 55 E. ERIE ST #2304, CHICAGO, IL, 60611 (which Trulia.com lists as a condominium), but it lists RTS’ phone number with a Wisconsin area code: 920-347-3838.

That’s the same phone number Ron Van Den Heuvel used for Green Box NA and other fraudulent entities at 2077 B, Lawrence Dr., De Pere, WI.

Due to ongoing investigations involving defendant and his companies, potential conflict issues have arisen. In light of potential conflicts, Mr. Van Den Heuvel and counsel agree that it is appropriate for Mr. Van Den Heuvel to be represented by other counsel in the above referenced matter. Mr. Van Den Heuvel advised [Atty. DePodesta] that he has spoken to other counsel regarding their representation of him in this and other matters.